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Polskie Linie Lotnicze "LOT" S.A.

PLL LOT S.A.

We are one of the 12 longest existing airlines in the world.

Lobbying Activity

Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)

14 Oct 2025 · Air passenger rights

Response to Sustainable transport investment plan

2 Sept 2025

Position of LOT Polish Airlines on Sustainable transport investment plan is attached. We fully recognize and support the need for aviations decarbonization in order to reduce pressure on the climate but there is a need for balanced, practical, and competitiveness-oriented measures in STIP. The plan should prioritize scaling SAF production, provide fair financing and regulatory conditions for airlines, and minimize administrative burdens.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

We appreciate the opportunity to comment on the functioning of the EU ETS. Please find our full position set out in the attached document.
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Response to Revision of EU rules on air services

11 Jun 2025

LOT Polish Airlines' Position on the Revision of the Air Services Regulation (Regulation 1008/2008) LOT Polish Airlines welcomes the opportunity to contribute to the ongoing discussion on the possible revision of the Air Services Regulation, which remains the cornerstone of the EUs internal air services market. See attached file with our position.
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

21 May 2025 · Impact of the EU law on the aviation competitiveness

Meeting with Dariusz Joński (Member of the European Parliament)

4 Feb 2025 · Presentation and discussion of aviation regulatory topics

Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)

4 Feb 2025 · Passenger rights in the context of multimodal journeys

Response to Rules for calculating price difference to kerosene and for EU ETS allocation of allowances for the use of eligible fuels

19 Dec 2024

LOT Polish Airlines appreciates the opportunity to provide feedback to the public consultation. Please see our comments in the attachment.
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Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)

14 Nov 2024 · Upcoming revision of aviation law and passenger rights

Response to ReFuelEU Aviation environmental labelling scheme

21 Oct 2024

LOT Polish Airlines welcome European Commissions ambitious climate goals. We believe that every passenger should have access to transparent and clear data regarding the environmental impact of their air travel. However, we have a few comments on the European Commission's proposal regarding the Environmental Labelling Scheme under the ReFuelEU Aviation initiative that are included in the attached document.
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Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55 (Batch 2)

19 Jul 2024

LOT Polish Airlines appreciates the opportunity to provide feedback on the draft of Commission Implementing Regulation amending Implementing Regulation (EU) 2018/2066 as regards updating the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council. We believe that the Monitoring, Reporting, and Verification (MRV) process of non-CO2 emission effects should be voluntary because current science and the proposed reporting framework are only based on estimates and not on an accurate data. It is necessary to have a scientific evidence that the measurements are conducted in the right way. In the case of contrails, for example, some may be warming, and others may be cooling. (based on the IATA in-depth report on aviation contrails and their climate effect) Unlike carbon dioxide emissions, which are calculated using an emission factor from the combustion of aviation fuel, calculating non-CO2 emissions is only an estimate and is based on complex calculations of various parameters, depending on the flight route, weather and climate conditions, as well as the composition of aviation fuel. For this reason, the result obtained is significantly different for each aviation operation, especially in the context of different assumptions and the quality of the data itself. Estimating results is contrary to the idea of data analysis, which is based on data exploration, modeling, and implementation. Therefore, the data obtained under MRV will inherently be limited and likely will not contribute to the reduction of non-CO2 emissions. The idea of introducing an MRV obligation for non-CO2 emissions raises concerns also due to the risk of changing the emission factor, which will significantly increase the costs of the aviation sector's participation in the EU ETS system. It should be noted that aviation sector is already highly financially burdened by the legislative changes that fit for 55 package has brought. It is also important to state that the MRV system will require airline operators to provide a multitude of data (air temperature, humidity, air pressure, solar radiation value, geopotential, etc.), for which access is non-systematic. There is a risk of creating a regulatory burden that will require airlines to incur significant financial expenditures to provide data with insufficient potential for a positive environmental impact. The scope of the MRV must be intra-EU only, to maintain consistency with the ETS scope for aviation. Any intention of expanding the scope to extra-EU international flights would raise legal concerns regarding extraterritorial effects. It is crucial to limit the scope of MRV exclusively to the area within the EEA to maintain consistency with the data reported under the EU ETS.
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Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55

23 Aug 2023

LOT Polish Airlines response to the proposed revision on EU ETS MRV regulation. In Article 54, paragraph 2, we believe that SAF volume should be used to reduce emissions from the flight for which it was tanked. This provision also lacks the information on how the evidence that the biofuel is attributed to the flight immediately following the uplift of the flight shall look like. In situation mentioned in Article 54, paragraph 3 we are of the opinion that the purchased fuel volume should be subtracted from the total emissions from the given airport subject to EU ETS accounting. In our opinion, the obligation to provide proof that biofuel was delivered to the fueling system should not be placed on the airline. We would like to point out that the revision lacks the definition of eligible fuels and there is no connection to ReFuelEU nor REDII.
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Response to Initiative on EU taxonomy - environmental objective

28 Apr 2023

As LOT Polish Airlines we believe that the aviation sector has great potential to introduce sustainable and environmental measures, and we support any initiatives put into it. However, the key element is to work out the final wording of the criteria in such a way that they are usable for the aviation industry and do not weaken the competitiveness of European carriers and do not limit the development of the aviation sector. Full response to the consultation is attached.
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Meeting with Henrik Hololei (Director-General Mobility and Transport) and Lufthansa Group and

28 Feb 2023 · Airlines operations in Japan